ML030160669

Amendment 242 to License DPR-50 Emergency Feedwater Technical Specification Change Request

ML030160669
Person / Time
Site:	Three Mile Island
Issue date:	01/16/2003
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Skolds J AmerGen Energy Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MB3660
Download: ML030160669 (17)

Text

January 16, 2003 Mr. John L. Skolds, Chairman and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1) RE: EMERGENCY FEEDWATER TECHNICAL SPECIFICATION CHANGE REQUEST (TAC NO.

MB3660)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendment No. 242 to Facility Operating License No. DPR-50 for the Three Mile Island Nuclear Station, Unit 1 (TMI-1), in response to your application dated December 19, 2001, as supplemented July 30, 2002, and November 14, 2002.

The amendment includes a revision of the Technical Specification (TS) Limiting Conditions for Operation (LCO) 3.4, Decay Heat Removal Capability, conforming changes to TS Table 3.5-2, Accident Monitoring Instruments, and TS 4.9.1.2, Decay Heat Removal - Periodic Testing, and numerous editorial changes. Specifically, the amendment:

• reflects the results of a benchmarked emergency feedwater (EFW) system flow analysis that was completed in August 1999,

• recognizes the concept of EFW flow path redundancy,

• incorporates a new LCO with operability requirements for the redundant steam supply paths to the turbine-driven EFW pump,

• incorporates the Standard Technical Specification (STS) requirement to initiate action immediately to restore EFW components and suspend all shutdown actions or changes in reactor operating conditions when the minimum required EFW capability does not exist,

• adds a note, similar to the one contained in the STSs, that permits a delay in performing the turbine-driven EFW pump surveillance in order to allow time to develop sufficient steam pressure for conducting the test, and

• improves the clarity of the TS requirements for the EFW system.

J. Skolds A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosures:

1. Amendment No. 242 to DPR-50

2. Safety Evaluation cc w/encls: See next page

J. Skolds A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosures:

1. Amendment No. 242 to DPR-50

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC PDI-1 R/F RLaufer TColburn EMarinos MOBrien DTrimble RDennig OGC ACRS GHill(2) BPlatchek, RGN-I SWeerakkody JTatum JBongarra DOCUMENT NAME: G:\PDI-1\TMI-1\AMDB3660.WPD ACCESSION NO.: ML030160669 *SE provided. No substantive changes.

OFFICE PDI-1\PM PDI-2\LA SPLB\SC* IEHB\SC* IELB\SC OGC PDI-1\SC NAME TColburn SLittle for MOBrien SWeerakkody DTrimble EMarinos SUttal RLaufer DATE 12/12/02 12/12/02 9/11/02 8/30/02 12/13/02 1/8/03 1/9/03 OFFICIAL RECORD COPY

AMERGEN ENERGY COMPANY, LLC DOCKET NO. 50-289 THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 242 License No. DPR-50

1. The Nuclear Regulatory Commission (the Commission or NRC) has found that:

A. The application for amendment by AmerGen Energy Company, LLC (the licensee), dated December 19, 2001, as supplemented July 30, 2002, and November 14, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.c.(2) of Facility Operating License No. DPR-50 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 242, are hereby incorporated in the license. The AmerGen Energy Company, LLC, shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 16, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 242 FACILITY OPERATING LICENSE NO. DPR-50 DOCKET NO. 50-289 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert ii ii iv iv 3-25 3-25 3-26 3-26 3-26a 3-26a 3-26b 3-26b 3-26c 3-26c

-- 3-26d 3-40b 3-40b 3-40c 3-40c 4-52 4-52 4-52a 4-52a

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 242 TO FACILITY OPERATING LICENSE NO. DPR-50 AMERGEN ENERGY COMPANY, LLC THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289

1.0 INTRODUCTION

By application dated December 19, 2001, as supplemented by letter dated July 30, 2002, and November 14, 2002, AmerGen Energy Company, LLC (the licensee), requested changes to the Technical Specifications (TSs) for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The licensees request is a new licensing action and supercedes a previous request that was submitted by letter dated December 6, 2000. The current submittal includes answers to questions that were asked by the Nuclear Regulatory Commission (NRC) during a June 19, 2001, telephone conference with the licensee regarding the December 6, submittal. The December 6, 2000, submittal is included for information as attachment 3 to the December 19, 2001, submittal. The supplements dated July 30, and November 14, 2002, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on March 19, 2002 (67 FR 12598).

The TMI-1 emergency feedwater (EFW) system supplies feedwater to the once-through steam generators (OTSGs) removing heat from the reactor coolant system to allow safe shutdown of the reactor during certain plant transients and design-basis accidents. The system consists of a single turbine-driven (TD) EFW pump and 2 motor-driven (MD) EFW pumps which normally take suction from the condensate storage tanks (CSTs) and discharge to a common header from which there is a supply line to each OTSG, each having 2 redundant flow control paths, a flow-limiting venturi, and a check valve.

The licensees submittal includes a revision of the TS Limiting Conditions for Operation (LCO) 3.4, Decay Heat Removal Capability, conforming changes to TS Table 3.5-2, Accident Monitoring Instruments, and TS 4.9.1.2, Decay Heat Removal - Periodic Testing, and numerous editorial changes. The proposed changes would revise the EFW section of the TSs and related Bases. The proposed changes would:

• reflect the results of a benchmarked EFW system flow analysis that was completed in August 1999,

• recognize the concept of EFW flow path redundancy,

• incorporate a new LCO with operability requirements for the redundant steam supply paths to the turbine-driven EFW pump,

• incorporate the Standard Technical Specification (STS) requirement to initiate action immediately to restore EFW components and suspend all shutdown actions or changes in reactor operating conditions when the minimum required EFW capability does not exist,

• add a note, similar to the one contained in the STSs, that permits a delay in performing the turbine-driven EFW pump surveillance in order to allow time to develop sufficient steam pressure for conducting the test, and

• improve the clarity of the TS requirements for the EFW system.

2.0 REGULATORY EVALUATION

The requirements pertaining to the TMI-1 EFW system were established primarily by the post-TMI Action Plan, as clarified by NUREG-0737, Clarification of TMI Action Plan Requirements, dated November 1980.

The NRC staffs review criteria related to the operator actions associated with the proposed license amendment are based on an adaptation of existing NRC review guidance for human factors engineering as found in: NUREG-800, "Standard Review Plan" (1996); NUREG-0711, Revision 1, "Human Factors Engineering Program Review Model" (2002); NUREG-0700, Revision 2, "Human- System Interface Design Review Guideline, (2002); Information Notice (IN) 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times" (1997); NUREG/CR-6689, "Proposed Approach for Reviewing Changes to Risk-Important Human Actions" (2000); Regulatory Guide (RG)1.174, "An Approach To Using Probabilistic Risk Assessment In Risk-Informed Decisions On Plant-Specific Changes To The Licensing Basis" (1998); RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decision Making: Technical Specifications," (1998); IN 91-18, "Information to Licensees Regarding Two Inspection Manual Sections On Resolution of Degraded and Non-Conforming Conditions and on Operability" (1991).

3.0 TECHNICAL EVALUATION

3.1 Systems Configuration Changes In addition to clarifying and improving the EFW TS requirements, the amendment request was submitted to satisfy a commitment that was made by GPU Nuclear (the previous owner of TMI-1) to update the EFW TS Bases.

The proposed changes to the TS requirements and editorial clarifications are discussed for the most part in the licensees December 6, 2000, submittal (Attachment 3 to the December 19, 2001, submittal), with a few additional TS changes added by the December 19, 2001, submittal.

These additional changes were proposed in response to questions that were asked by the NRC during the preliminary review of the December 6 submittal, and incorporate additional

requirements that are consistent with the STSs and provide a more appropriate and complete LCO. These additional changes are applicable to TS LCO 3.4.1.1.a, and include:

• a requirement is added to initiate action immediately to restore at least two EFW pumps and one EFW flow path to each once-through steam generator (OTSG) to operable status when the minimum required EFW capability does not exist. In the interim, any actions requiring shutdown or changes to reactor operating conditions are suspended.

The purpose of this requirement is to minimize to the extent possible any plant changes or perturbations that could result in the need for decay heat removal when the safety-related means of accomplishing this function is not available. The proposed change is acceptable.

• an allowed outage time (AOT) of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is added for when one steam supply to the TD EFW pump is inoperable at the same time that one of the MD EFW pumps is inoperable. While the EFW system would be able to perform its safety function during most accident and transient conditions when in this condition, a main steam line break or a main feedwater line break could affect the operable steam supply to the TD EFW pump and jeopardize the functionality of the EFW system. Consistent with the AOT time frames established in the STS, a 24-hour AOT is considered to be appropriate and acceptable for this condition.

• a provision is added to defer testing of the TD EFW pump for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 750 psig steam pressure in the OTSGs. This provision is consistent with what is allowed by the STS, and is necessary to allow time to complete the surveillance after sufficient steam pressure has been obtained in the OTSGs. This change is considered to be appropriate and acceptable.

Most of the TS changes that were originally proposed in the licensees December 6, 2000, submittal are editorial in nature and are considered to be acceptable on that basis. Changes that were proposed in the December 6, 2000, submittal with respect to TS LCO 3.4.1.1.a that are more substantial, requiring specific NRC attention, include:

• use of revised wording to define and clarify the concept of EFW flow path redundancy as described in the TS Bases, which states: Flowpath redundancy is provided for those portions of EFW flowpath containing active components between the pumps and each of the OTSGs. Each EFW line to an OTSG includes two redundant flowpaths each equipped with an automatic control valve (EF-V-30A/B/C/D) and a manual isolation valve (EF-V-52A/B/C/D). The concept of EFW flow path redundancy as described in the TS Bases and applied in the TS LCO is consistent with the plant design and is considered to be acceptable.

• a 7-day AOT is added for when one of the two main steam supply lines to the TD EFW pump is inoperable. This clarifies the issue of whether an operable steam supply system requires the operability of the steam supplies from both OTSGs. With one of the steam supply lines inoperable, the EFW system is still able to mitigate most postulated accident conditions while still assuming a single active failure. However, in the event of a main steam line break or a main feedwater line break, the operable steam supply for the TD EFW pump could be affected such that a single active failure could not be

tolerated. A 7-day AOT for this situation is consistent with the guidance provided in the STS, and is considered to be appropriate and acceptable for application at TMI-1.

• a 72-hour AOT with any EFW pump or flow path inoperable. This is more conservative than the current TS, since the current TS would permit continued operation with up to one redundant flow path to each OTSG inoperable. Therefore, this change is considered to be acceptable.

• changes that revise and clarify EFW pump and flow path operability requirements during surveillance testing. The existing restriction specified by TS Surveillance 4.9.1.2 is relocated to TS LCO 3.4.1.1.a(4), Note 2(b), because it relates more directly to EFW system operability than to surveillance testing. The original wording is revised as described in the December 6, 2000, submittal, as modified by the December 19, 2001, submittal, to: (a) reflect the revised concept of EFW flow path, (b) allow the dedicated operator to be in the immediate vicinity of the affected EFW local manual valves instead of at the valves, and (c) allow the need for system restoration to be communicated from the Control Room instead of from the Control Room Operator.

The proposed changes as discussed in the submittals (primarily the licensees response to Question 3 in Attachment 1 of the December 19, 2001, submittal) preserves the intent of the original requirement, while allowing additional operator flexibility in completing the required TS surveillance. The proposed changes are considered to be acceptable.

• clarifies the requirement for EFW operability during periods when the heat sink protection system (HSPS) is not required to be operable. The double asterisk at the bottom of TS Page 3-25 is revised to state: When HSPS is not required to be OPERABLE, EFW is OPERABLE by manual control of pumps and valves from the Control Room. This is an editorial change which does not alter the existing TS requirement, and the clarification is considered to be acceptable.

• revises the EFW system design basis with respect to pump capacity. As a result of revised steam generator tube plugging limits, a single TD EFW pump may not have sufficient capacity to satisfy the most limiting EFW flow requirements and a MD EFW pump must also be credited. However, the TD EFW pump remains able to satisfy EFW flow requirements that result from a loss of all AC power. The changes that are proposed in this regard are consistent with the NRC staffs approval of License Amendment No. 214, dated August 19, 1999, and are therefore acceptable.

• revises the EFW system design basis with respect to the cooldown capability afforded by the amount of water stored in the CSTs. The current Bases states that the minimum water volume in the condensate storage tanks will allow cooldown to 250 EF with steam being discharged to the atmosphere. This is being revised to indicate that the minimum required amount of water in the CSTs provide at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of decay heat removal with steam being discharged to the atmosphere. Recent analyses show that because the cooldown rate is slowed down when steam is being released to the atmosphere with reduced steam pressure, additional water beyond what was originally assumed to be available in the CSTs is needed to complete the cooldown to 250 EF. However, the licensee has determined that the minimum required amount of water in the CSTs will support at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of decay heat removal. This is enough time to align alternate water sources that are available and if necessary, an unlimited supply of river water can

be made available for steam generator cooling via the reactor building emergency cooling water system. Therefore, this change is considered to be acceptable.

3.2 Conforming Changes to TS Table 3.5-2, Accident Monitoring Instruments Item 4 in Table 3.5-2 is being revised to require 2 flow indication channels to each OTSG to be consistent with the revised flowpath definition. The EFW system has two flow instruments on the common line between the redundant EFW flow control valves and the OTSG. The current TS Bases indicate that the intent of this specification is to reflect 2 flow indication channels on each of the 2 common discharge lines (one to each OTSG). The Accident Monitoring Instrumentation TS requirement (TS 3.5, Table 3.5-1) currently requires 2 flow indication channels per each EFW flowpath. Therefore, this change does not affect the intent of the LCO and is therefore, acceptable.

3.3 Operator Actions In their December 6, 2000 submittal, the licensee proposed to revise TS 3.4, "Decay Removal,"

sub-step 3.4.1.1, a. (1)-(4) to indicate as TS sub-step 3.4.1.1.a, (4) While performing surveillance testing, more than one EFW Pump or both flow paths to a single OTSG may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided that:

(a) At least one motor-driven EFW pump shall remain OPERABLE.

(b) With the reactor in STARTUP, HOT STANDBY, or POWER OPERATION, a qualified individual, in communication with the control room, shall be designated to remain continuously near the location required to realign the affected valves from the test mode to their operational alignment upon instruction from the Control Room.

Otherwise, be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The NRC staff requested additional information (RAI) regarding the licensees December 6, 2000, submittal during a June 19, 2001, conference call. As part of the licensees December 19, 2001, submittal, the licensee responded to the RAI (see Attachment 1 of the licensees December 19, 2001 submittal). RAI question 3 (and related question 4) identified that the TS sub-step 3.4.1.1.a (4)(b) proposed by the licensee in their December 6, 2000, submittal, "is a significant relaxation from what was originally approved, and the proposed change has not been adequately justified." and questioned why more than one EFW is needed to be inoperable.

In response to the NRC staffs RAI questions, the licensee revised TS 3.4, sub-step 3.4.1.1.a (4)(b), by inserting a note, 2. (b), in the sub-step to indicate that, With the reactor in STARTUP, HOT STANDBY, or POWER OPERATION, a dedicated qualified individual who is in communication with the control room shall be continuously stationed in the immediate vicinity of the affected EFW local manual valves. On instruction from the Control Room, the individual shall realign the valves from the test mode to their operational alignment.

In its response, the licensee explained that the change from "designated" to "dedicated qualified individual" was made to identify that the individual is "involved exclusively with EFW surveillance testing." The licensee further stated that this change allows that individual to be actively involved in the EFW surveillance tests (e.g., pump operation monitoring, valve stroke testing) and therefore maintain a heightened awareness of the EFW System status by communication with the Control Room.

The licensee further indicated, in their December 19, 2001, submittal as a revision to the Decay Heat Removal TS Bases that, if the EFW system is needed during surveillance testing, because the normal feedwater supply is unavailable, "minor operator action (e.g., opening a local isolation valve or manipulating a control switch from the control room) may be needed to restore operability to the required pumps or flow paths." To allow more than one EFW pump or both EFW flow paths to a single OSTG to be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during surveillance testing, the licensee proposed that at least one motor-driven pump is operable and that, "an individual dedicated to the task of testing the EFW System must be in communication with the control room and stationed in the immediate vicinity of the affected EFW flow path valves.

Thus, the individual is permitted to be involved in test activities by taking test data and his movement is restricted to the area of the EFW pump and valve rooms where the testing is being conducted."

The NRC staff reviewed the licensees December 19, 2001, submittal and issued an RAI on May 23, 2002, requesting further information on crediting operator action for realigning the EFW flow isolation valves. The licensee responded to the RAI on July 30, 2002. In the RAI, the staff requested the licensee to identify the minimum amount of time available to manually realign the EFW flow isolation valves to their operational positions if an EFW transient occurred while performing the surveillance test. The staff also requested the licensee to describe the basis for determining that an individual can successfully and reliably realign the EFW flow isolation valves to their operational positions if an EFW transient occurred while performing the surveillance test and identify the consequences if the valves are not realigned.

In response to the staffs first question, the licensee indicated that, "TMI Unit 1 does not have specific design or licensing basis requirements for the minimum allowable time for an individual to realign EFW valves." However, the consequences of a failure to realign them "would not lead to core damage." The licensee explained that they have "evaluated the anticipated operator response time associated with an event of an EFW transient while surveillance testing was being performed." The proposed TS 3.4.1.1.a (4) surveillance testing related to realigning EFW valves is also associated with two principal surveillances, inservice testing (IST) of the motor-driven EFW pumps and the HSPS automatic initiation surveillance, both surveillances conducted quarterly.

In the case of the IST, the licensee estimated, "that restoration of the EFW flow path to the isolated steam generator is completed within 4 minutes. This time estimate is based on the opening operation of 1 of the 2 closed EFW-V-52 manual isolation valves in one flow path, and operator proximity to the valves during testing." The IST testing isolation valves (EF-V-52A/B/C/D) are located in the motor-driven EFW pump room, which is immediately adjacent to the associated pumps. The valves for each steam generator are located within 20 feet of each other, have no interferences in their paths to hinder travel of an operator and are

located at an elevation convenient for operator manipulation. The licensee indicated that the "valves operate easily with the installed hand-wheelvalve operation (from open to close or vice-versa) is observed to take about one minute to complete during surveillance testing.[and]

no special tools or ladders are required to operate or reach the valve hand-wheels."

During testing of the HSPS automatic initiation logic, both the turbine-driven pump and one motor-driven pump (MDP) are made inoperable. The MDP is made inoperable by either placing the control switch in the pull-to-lock position or by closing the pumps discharge isolation valve (EF-V-10 A/B). The licensee indicated that restoring the MDP from the pull-to-lock position takes an estimated 2 minutes and restoring the MDP from the discharge isolation valve closed position is completed within 3 minutes. The HSPS test isolation valves are hand-wheel operated and are observed during surveillance testing to take about 1 minute to operate. No special tools or ladders are required to reach the valve hand-wheels. The licensee also indicated that the expected manual valve realignments for the EFW system would not be hampered by harsh environmental conditions. The licensee analyzed a high-energy line break inside the Intermediate Building, a main steam line break, and a Feedwater Line Break as credible accidents that would effect the EFW environment and determined that various system responses would preclude the need for manual actions.

The licensee further qualitatively assessed the consequences of failing the required manual valve alignment in transients that credit EFW for heat removal. The Loss of Feedwater, Small Break Loss of Coolant, and Feedwater Line Break accidents were evaluated and determined that no core damage is expected if the manual actions are failed.

Finally, in response to the NRC staffs question related to properly identifying the individual performing the manual actions as a "dedicated" versus a "designated" individual, with the "dedicated" individual being solely responsible for the valve manipulations, the licensee revised its December 19, 2001, submittal to state, "designated" qualified individual rather than "dedicated" individual. The change is consistent with the licensees December 6, 2000, submittal and indicates that the individual can be involved in the EFW testing as well as being responsible for the required manual valve realignments, as needed. The licensee revised their TSs and associated Bases to reflect this change.

The NRC staff has determined that the information included in the licensees application and supplement related to crediting of operator actions supports the proposed change. Therefore, the NRC staff has determined that the proposed change is acceptable.

3.4 Editorial Changes The licensee proposes dozens of editorial changes throughout the proposed license amendment. These include the addition and definition of numerous acronyms for various systems and components, spelling out symbols such as degrees, adding phrasing and spelling of words consistent with other TSs, deleting redundant phrasing, correcting grammatical errors, adding page breaks, and consistent use of upper case lettering for defined terms. The NRC staff has reviewed the proposed editorial changes and has determined that they are indeed of minor editorial nature and are therefore, acceptable.

Based on the NRC staffs review of the licensees request, as discussed above, the NRC staff considers the proposed changes to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (67 FR 12598). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Tatum J. Bongarra T. Colburn Date: January 16, 2003

Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Nuclear Senior Resident Inspector (TMI-1)

Station, Unit 1 U.S. Nuclear Regulatory Commission AmerGen Energy Company, LLC P.O. Box 219 P. O. Box 480 Middletown, PA 17057 Middletown, PA 17057 Director - Licensing - MId-Atlantic Regional Senior Vice President Nuclear Services Operating Group AmerGen Energy Company, LLC AmerGen Energy Company, LLC 4300 Winfield Road Nuclear Group Headquarters Warrenville, IL 60555 Correspondence Control P.O. Box 160 Vice President - Mid-Atlantic Operations Support Kennett Square, PA 19348 AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Rich Janati, Chief Kennett Square, PA 19348 Division of Nuclear Safety Bureau of Radiation Protection Senior Vice President - Department of Environmental Protection Mid Atlantic Regional Operating Group Rachel Carson State Office Building AmerGen Energy Company, LLC P.O. Box 8469 200 Exelon Way, KSA 3-N Harrisburg, PA 17105-8469 Kennett Square, PA 19348 Three Mile Island Nuclear Station, Unit 1 Vice President - Plant Manager Licensing and Regulatory Affairs AmerGen Energy Company, LLC AmerGen Energy Company, LLC P. O. Box 480 4300 Winfield Road Middletown, PA 17057 Warrenville, IL 60555 Regulatory Assurance Manager - Three Mile Regional Administrator Island Nuclear Station, Unit 1 Region I AmerGen Energy Company, LLC U.S. Nuclear Regulatory Commission P.O. Box 480 475 Allendale Road Middletown, PA 17057 King of Prussia, PA 19406 John F. Rogge, Region I Chairman U.S. Nuclear Regulatory Commission Board of County Commissioners 475 Allendale Road of Dauphin County King of Prussia, PA 19406 Dauphin County Courthouse Harrisburg, PA 17120 Michael A. Schoppman Framatome ANP Chairman Suite 705 Board of Supervisors 1911 North Ft. Myer Drive of Londonderry Township Rosslyn, VA 22209 R.D. #1, Geyers Church Road Middletown, PA 17057

Three Mile Island Nuclear Station, Unit 1 cc: continued Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1-N Kennett Square, PA 19348 Manager Licensing - Oyster Creek and Three Mile Island AmerGen Energy Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348